ML20072J102
| ML20072J102 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 01/08/1982 |
| From: | Potts W GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-02, TASK-03, TASK-06, TASK-2, TASK-3, TASK-6, TASK-GB NUDOCS 8306290927 | |
| Download: ML20072J102 (77) | |
Text
I dab 177 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . - - _x GENERAL PUBLIC UTILITIES CORPORATION, :
JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and :
PENNSYLVANIA ELECTRIC COMPANY, .
Plaintiffs, 80 CIV. 1683
- (R.O.)
-against-
~
THE BABCOCK & WILCOX COMPANY and J. RAY McDERMOTT & CO., INC., :
Defendants. t :
-. . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x
3 Continued deposition of WILLIAM E.
)
POTTS, taken by Defendants, pursuant'to adjournment, at the offices-of Davis Polk &
Wardwell, Esgs., One Chase Manhattan Plaza, New York, New York, on Friday, January 8, 1982, at 9:45 o' clock in the forenoon, before Robert Capuzelo, a Shorthand Reporter and Notary Public within and for the State of New York.
8306290927 820108 PDR ADOCK 05000289 T PDR (3 J \
'v DOYLE REPORTING. INC.
CERTIFIED STENOTYPE REPORTER!
369 LExlNGTcN AVENUE WALTER SH APIRO, C.S.R.
NEW Ye m k. N.Y. 1C017 CHARLES SHAPf RO, C.S.R.
TELEPHONE 2I2 " 867 8220
I
-1 178 t .
2 APpea ran ce s:
3 KAYE, SCHOLER, FIERMAN, HAYS &' HANDLER, ESQS.
Attorneys for Plaintiffs 4
4 425 Park Avenue New York, New York 5
C By: MYRO$ KIRSCHBAUM, ESQ.,
6 of Counsel 7
! 8 d'
9 DAVIS POLK & WARDWELL, ESQS.
Attorneys for Defendants 10 One Chase Manhattan Plaza g i New York, New York 10005 -
11 l By: KAREN E. WAGNER, ESQ.,
12 q of Counsel
(/ 13 14 15
- 16 Also Present
17 SUSAN HANSON, Paralegal Davis Polk & Wardwell, Esgs . '
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18
- 19 20 21 22 23 I
t O 4 25
. I v .
. - . . . . _. _ , - . . _ _ _ _ _ _ ~ . _ _ _ _ _ - _ - - _ . ~ . - . _ . - - . , - . - - - - - - -
1 l
l 1 179
[ t
\~l 2 WI LL IAM E. P OTT S, resumed, having 3 been Previously duly sworn, was examined and 4 testified further as follows:
5 MR. KIRSCHBAUM: Last night I had an 6 Opportunity to discuss with Richard Seltzer,who 7 has taken a large number of the depositions in 8 this action, my instruction to the witness 9 yesterday not to answer certain questions 10 concerning his understanding of pertain matters.
11 Mr. Seltzer informed me that Davis, Polk 12 has now taken to citing our instructions of that O)
(_ 13 nature which were themselves int' ended as a response
~
14 *to their instructions of that nature as a further 15 Pretext for continuing the practice which we have 16 from the outset disapproved of, that is, the 17 Practice of instructing the witnesses not to
~
18 answer.
19 TherefoTe, in the interest and the hope of 20 having both sides permit their witnesses to 21 answer questions of that nature, we have decided 23 to withdraw that objection, that series of 23 objections and the witness will be permitted 24 to answer questions as to his understanding of 25 matters such as those covered in certain questions
r.
1 Potts 180
?
' yesterday.
2 3 MS. WAGNER: Thank you for your statement.
4 EXAMINATION (Cont'd.)
5 BY MS. WAGNER:
([
6 Q Mr. Potts, are you aware that you are.still 7 under oath today?
8 A Yes.
9 Q Have you ever heard of somebody who worked 10 at Three Mile Island called A. R. Joyce?
1 11 A I don't recall that name.
12 Q How about C. J. Hagerty?
C-I 13 A I don't recall that name. I 14 Q M. J. Perlmutter?
15 A No, I don't recall that name.
16 Q F. J. Mulligan?
17 A No. ,
18 Q Or E. C. Fuller?
19 A No.
20 Q I would like to show you now a document 21 which has been previously marked as part of an exhibit, k.'
22 B&W 208. These are selected pages from that exhibit and 23 these pages are a portion of the issue of " Nuclear
[~D 24 Power Experience" dated July 1978. It concerns the L.)
25 Davis-Besse transient in September of 1977.
1
l l
1 I
l 1 Potts 181
,. . 1 N~ l <'
2 I would like you to review the document 3 and tell me if you have ever seen it before, this 4 Particular document.
( 5 MS. WAGNER: I will note this is a microfilmed 6 version reduced in size. -
7 Q If you.saw the original, it probably would 8 have looked a little larger. i 9 MR. KIRSCHBAUM: Is this B&W 208 or part ;
1 1
10 of 2087 t I 11 MS. WAGNER: Part.
12 MR. KIRSCHBAUM: Is there any reason not to i \- li show the witness the entire exhibit?
l A
14 MS. WAGNER: I don't believe the witness l 15 has any familiarity with -- let's go off the 16 record.
I 17 (Discussion off the' record.),
18 A I don't recall this document.'
i 19 Q Do you recall having seen issues of i 20 " Nuclear Power Experience" other than this one?
21 A Is this from " Nuclear Power Experience"?
22 Q My understanding is that it is, yes.
23 A I don't recall " Nuclear Power Experience."
\
24 It's not stated here.
LI 25 Q I think there is a little title in the lower
1 Potts 182
(") .
Q left-hand corner which is entirely illegible but I 2
3 believe that is what the document says.
4 MR. KIRSCHBAUM: Where?
( 5 MS. WAGNER: I'm sorry, the lower right-hand 6 corner.
7 MR. KIRSCHBAUM: On our copies, I would have 8 to say that is completely illegible.
4 9 Q Do you recall having seen " Nuclear Power J 10 Experience"? i .
11 A I don't recall " Nuclear Power Experience,"
12 no.
\" 13 Q Mr. Potts, we had talked s metime yesterday 14 about the GRC-2. ,
15 Do you recall that GRC-2 was responsible I
16 for reviewing procedures for TMI-27 17 A I recall from the documents y,ou showed me 18 yesterday that the GRC had some responsi[ility of 19 reviewing procedures but prior to seeing that document, 20 I don't recall.
21 Q You don't recall yourself reviewing 22 procedures as part of GRC-2's function?
23 A No.
(L./) 24 MR. KIRSCHBAUM: I think it should be noted 25 the witness testified yesterday he didn't recall
1 Potts 183
-A N. -
g being on GRC-2.
3 Q Mr. Potts, during any time that you were 4 employed at Metropolitan Edison prior to the time of the
( 5 accident, did you become aware of any instances in 6 which TMI-2 suffered a react.or trip because of condensate 7 Polisher problems?
8 A I don't recall being aware of that at any 9 time.
10 Q Did you have any discussioh,s at any time 11 with respect to the condensate polishing systems of 12 TMI-2,?
4
() 13 MR. KIRSCHBAUM: Pre-accident?
l 14 MS. WAGNER: Yes, and with anybody.
- 15 A I don't recall,those discussions, if I had 16 any.
17 Q Do you recall whether during.the time that 18 you were supervisor of Licensing there was any discussion 19' concerning a bypass of the condansate polishing system' 20 in TMI-27 21 A No.
22 Q Did you have any understanding then as to 23 whether if.such a bypass of this condensate polishing
[q,h, 24 system were being considered, that would have been a 25 matter that Licensing would have reviewed?
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l Potts 184
~
V(^h 2 MR. KIRSCHBAUM: An understanding when he 3 was supervisor of Licensing?
4 MS. WAGNER: Yes.
C. '5 A Ask your question again for me, please.
6 Q When you were supervisor of Licensing, did 7 Licensing have any respon'sibility for reviewing changes 8 in the hardware of TMI-27 9 A Yes, if those would have required submittal 10 to the regulatory bodies. E i
l 11 Q would any change in a piece of equipment 12 which was related to the nuclear steam supply system 13 have required such a report to the regulatory bodies?.
14 MR. KIRSCHBAUM: Any or all?
15 MS. WAGNER: Any. All, I guess, is what I-16 mean. All.
17 A I don't recall if all would have.
18 Q But you do recall that some would have?
19 A Yes.
20 Q Do you recall whether or not a change which 21 would have resulted in a bypass of the condensate 22 polishing system was a matter such as would have to be 23 reported to the regulatory bodies?
(j 24 MR. KIRSCHBAUM: Are you asking if he recalls 25 now as~a supervisor of Licensing to that effect?
1 Potts 185 (h
\_] '
2 MS. WAGNER: Right.
3 A I d n't recall now.
4 Q During the time period you were supervisor
( 5 of Licensing, did it ever come to your attention that 6 an event had occurred at TMI-2 which resulted in the 7 trapping of the steam in the hot leg or hot legs of 8 TMI-27 9 A No.
10 Q Prior to the time that fuel was loaded into 11 TMI-2, was there any method similar to the licensee 12 event report system by which transients would be 13 reported to the NRC7 14 MR. KIRSCHBAUM: Read the question back, 15 please. ,
! 16 (Record was read back.)
17 A I don't know. .
18 Q You have no recollection at this time that 19 during the time you were supervisor of Licensing there J
20 was any such system in place?
21 A That's correct.
22 Q Do you recall an event which occurred at 23 TMI-2 in April of 1978 which resulted in a reactor trip 24 and cooldown of the system?
25 A I don't recall April.
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1 Potts 186
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2 Q Do you recall such an event, a cooldown 3 caused by steam relief valves opening?
4 A Yes.
l ( 5 Q How did you first hear about that event?
l 6 A I don't recall how I first heard about it.
7 Q Do you recall who told you about it?
8 A No.
9 Q Do you think you were in the control room 10 at the time?
I 11 A No, I was not in the control room.
12 What did you hear about the event?
Q 13 MR. KIRSCHBAUM: Pre-accident?
14 MS. WAGNER: Pre-accident.
15 A I don't know what caused the trip but during ,
16 the trip, the steam relief valves opened and several 17 failed to reseat or close. -
18 Q Lo you recall hearing anything else about 19 the event?
20 MR. KIRSCHBAUM: Pre-accident?
21 MS. WAGNER: All my questions are 22 pre-accident.
23 'A Pressurizer level was very low .and there it was a discussion as to was it below indication'or below---
25 did it leave the pressurizer.
1 Potts 187
%J 2 ,
Q Is this the same discussion that you were 3_ testifying about yesterday toward the end of the day?
4 MR. KIRSCHBAUM: Objection. I don't believe the witness has in front of him the testimony
(' 5 6 from yesterday and, therefore, I am not clear 4
7 that he would know what you are referring to 8 precisely.
i 9 Q Do you recall anything else about the effect 10 of this transient on the primary system of TMI-27 11 A The effect was a shutdown and an engineering 12 effort on the relief valves that consumed some period of '
time.
13 I don't recall the period of time.
14 Q Do you recall having heard anything else 15 about the effect of the transient on the fluid in the 16 - Primary system?
17 A There was also an analysis or a discussion 18 as to whether or not a bubble had developed undern'eath 19 the reactor head.
i
~
l 20 Q Was any conclusion reached?
. 21 A There was a conclusion reached by B&W that a 22 bubble was not drawn and there was a conclusion reached 23 by GPU that a bubble was drawn and they were in the
\
4
[A 24 Process of discussing which was,-in fact, the case.
a:s
- 25. Q Did the Licensing Department play any role y _ _ _ _ _ _ , . , , , _ . . . , . , , _ , - - ,
e .* wrt ---e-- r
1 Potts 188 O 2 in the analyses or discussions with respect to the t
3 bubble? -
4 A No.
( 5 Q To the best of your recollection, did this 6 transient result in the filing of any 10 CFR Part 21 7 reports?
- 8 MR. KIRSCHBAUM: By anyone?
g MS. WAGNER: By Metropolitan Edison or 10 General Public Utilities. L 11 A I don't recall.
12 Q I will show you a document previously O 13 m9rked as Defendants' Exhibit 186.
It is a task force 14 report also known as TDR 001 concerning the April 23rd 15 transient. It is the first document in this notebook 16 here.
17 I would like to ask you whether you have 18 ever seen that document before?
19 MR. KIRSCHBAUM: TDR 0017 20 MS. WAGNER: Yes.
21 Q You are welcome, of course, to read the 22 whole document. But if you have any recollection 23 having read what you have now whether you have ever (J). 24 seen it before, perhaps that would help.
25 A I don't reca13 having seen this document l
1 Potts 189
(~ '
i N_) )
Prior to the accident, but it's the incident we were 2
3 discussing this morning, the turbine bypass valves ---
4 excuse me, the turbine relief valves.
( 5 Q You don't recall having been part of the 6 task force that generated this document?
7 A That's correct. I was not part of the task
, 8 force.
9 Q And you don't think you saw it before the 10 accident, the report? t 11 A I don't recall having seen it.
1 12 s Q I would like you to turn to the page which 1 13 is l- 1cok at the lower right-hand corner at the 14 production number, the page is 12470585. That is about 15 half way through the document.
16 This document has been previously identified 17 as a report done at Metropolitan Edison.concerning the 18 same incident. I would like to ask you'if you recall
~
19 seeing this particular document independently of the 20 task force report.
6 .
^
21 ,
MR, KIRSCHBAUM: What are we re'forring to,
(-
22 A'tnachment x
17 e
23 ) MS. WAGNER: Yes.
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s/
) 24 .~MR. KIRSCHBAUM: In its entirety?
25 MS. WAGNER: In its entirety. % s v% %,."
'Q
1 Potts 190 O
~
2 MR. KIRSCHBAUM: The question is whether 3
he recalls seeing that separate from the entire 4 task force report?
( 5 MS. WAGNER: Yes. It is part of the task 6 force report but it was also issued > independently 7 of the task force report.
8 A I don't recall seeing this prior to the 9 accident.
10 Q Do you recall being part o.f a group who was 11 reviewing this transient, a group at Met Ed as opposed 12 to GPU?
O .
13 A No.
14 Q Finally, I would like you to turn to 15 production page number 12470617 which is a letter from 16 Babcock & Wilcox to G. P. Miller dated May 2, 1978 and 17 I would like to ask you if you have seen,that letter
~
18 before.
19 MR. KIRSCHBAUM: In my copy s'omething is 20 wrong. I have '0 663 which doesn't appear to be 21 Part of the letter to Mr. Miller and following 22 that is '0 618.
23 MS. WAGNER: Off the record.
[ ) 24 (Discussion off the record.)
L.) ,
25 Q The letter to which I am referring is d
1 Potts 193 2
12470617 through '0623.
3 'MR. KIRSCHBAUM: This letter is, I see --
4 it follows a page which says " Appendix D." Are
( 5 you asking if he saw this letter separate from 6
the appendices? Just this letter?
7 MS. WAGNER: That's right.
O A One of the attachments mentioned in the 9 letter is not within the number of pages that you gave
, 10 me, I~ don't think. .
11 I don't recall having seen this letter prior 12 to the accident.
0 .
13 Q Did you see it after the accident?
14 A I don't recall having seen the letter after 15 the accident, no. ,
16 Q I would like to refer you now, please, to 17 a document which was previously marked as B&W 188. That l 18 is under tab 2 in the notebook, TDR No. 006, and is 19 entitled "EPRI RETRAN Working Group," and it is an 20 analysis of the April 23rd transient, also.
l 21 Again, my question is, have you seen this 22 document before?
23 A I don't recall having seen this document.
l A
24 The first page of the document indicates Q
25 that you were on a distribution list but to be sent the
1 Potts 192 2 cover page only.
- \
3 Do you recall having seen the cover page?
4 A I don't recall having seen the cover page.
l 5 Q Do you know any reason why you would be sent 6 this cover page without any attachments?
7 A No, I don't.
8 Q Do you know what RETRAN is?
9 A Yes.
10 Q What is it? E 11 A It's a computer code.
12 Q Were you ever involved in using that O 13 computer code?
14 A No.
15 Q Were you aware that the computer code had 16 been used in some respect with regard to the April 23rd l 17 transient? .
- 18 MR. KIRSCHBAUM: Was ~ he aware before the 1 -
10 accident?
[
20 MS. WAGNER: Before the accident, yes.
-21 A I'm not certain about the' April 23rd part.
22 I was aware RETRAN was used.
With respect to the overcooling _ transient 23 Q 24 we spoke about?
25 A The overcooling from the< turbine relief
1 Potts 193 0,.. l 2 valves. '
3 Q Did you know prior to the accident why a 4 RETRAN analysis would have been done of the overcooling
( 5 transient?
6 A I don't recall why it was used.
7 Q Do you recall having learned any conclusions 8 reached as a result of the use of the RETRAN code?
9 MR. KIRSCHBAUM: Does he recall --
10 MS. WAGNER: Before the adyident.
11 MR. KIRSCHBAUM: Does he recall hearing of 12 the conclusions as a result of the RETRAN code
~
13 being used? _
14 MS. WAGNER: Right.
15 A As I testified earlier, there were some e
16 results that were questioned between B&W and GPU on 17 this cooldown. .
18 'Q Have you understood that the results, that 19 the conclusion that GPU had reached was as a result of 20 using the RETRAN code?
21 A Yes.
22 Q How did you learn about that conclusion?
23 A I don't recall how I learned of that.
) 24 \ Q. Is it correct that you testified that the 25 conclusion;GPU came to was that a bubble had formed in m.--g- , g
l 1 Potts 194
(~~ ~
(_
g the upper head of the reactor during the transient?
3 A Yes.
4 Q Did you have any conversations with anybody
( 5 concerning that conclusion?
6 A I just don't recall whether that is how I 7 found out, by way of conversation or how.
8 Q Regardless how you found out about it, do 9 you recall whether you spoke about it with anybody?
10 A No. E 11 Q Did that conclusion cause you any concern?
12 A I don't recall whether it caused concern or 13 not.
14 Q Was it your understanding at the time that 15 it was appropriate in the operation of a nuclear reactor 16 to have bubbles forming in the upper head of the reactor 17 vessel? .
18 MR. KIRSCHBAUM: I am not sure I understand 19 what you mean by " app r op ri a te " in the context of 20 that question.
21 Q Do you believe that was something that should 22 happen during the normal course of operation of a nuclear 23 reactor either at power or in some other state.of its O( 7 24 operation?
25 MR. KIRSCHBAUM: I don't understand what
1 Potts 195 O
\j-2 you mean by something that should happen.
3 Something that should happen as a natter of 4 course?
. 5 Q ,
Is it something the system is intended to l 6 do? Is that the way it is supposed to be run?
7 MR. KIRSCHBAUM: Objection to the form.
8 A I don't recall if I came to that conclusion l
9 or not.
I 10 Q You don't recall having ha"d any understanding I
11 at that time of whether or not having a bubble in the 12 upper head of the reactor vessel was a good or bad 10 13 thing?
14 MR. KIRSCHBAUM: Objected to as to form.
15 A I don't recall that.
16 Q Do you recall how you heard about the B&W 17 conclusions with respect to this transient and with 18 respect to where the bubble had been generated?
19 MR. KIRSCHBAUM: Objection. I don't know l 20 whether that is a correct characterization of 21 what the witness had testified hearing concerning 22 B&W's conclusion.
23 Q What did you hear about B&W's conclusion
() 24 with-respect to a bubble?
25 A I recall hearing B&W came to the conc 1'usion
1 Potts 196 v 2 that a bubble did not form and that GPU came to the 3 conclusion that it did form.
4 Q Do you recall how you learned about B&W's
( 5 conclusion?
6 A No.
7 Q Do you recall having any discussions with 8 anybody about B&W's conclusion?
9 A No.
10 MR. KIRSCHBAUM: I am taki'ng these 11 questions whether he recalls one way or the other.
12 MS. WAGNER: Yes.
' 13 Q Do you recall whether there was any 14 conclusion reached by GPU concerning whether or not the 15 pressurizer had emptied during the transient?
16 A No.
17 Q Do you recall any conclusion. reached by 18 anybody else as to whether or not the pressurizer had 19 emptied?
20 A Yes.
21 Q Who reached any conclusion with respect to 22 that?
23 A The plant staff reached the conclusion it 24 had not emptied, that it had gone below the indicated 25 level.
1 Potts 197 m .
i
)
2 Q That is the Metropolitan Edison plant staff?
s 3
A TMI plant staff.
4 Q Do you recall whether the TMI plant staff
(' 5 reached any conclusion with respect to whether or not 6 a bubble had been drawn or generated in the primary 7 system during this transient?
8 A No.
9 Q Yesterday you testified concerning meetings 10 which you recall being held at B&W conqerning the small 11 break LOCA problem and fix.
. 12 Do you recall how many meetings you attended 13 which concerned that issue? ,
14 A No.
15 Q Do you recall the dates of any of the 16 meetings?
17 A No. .
18 Q Do you recall whether anybody else from 19 Metropolitan Edison attended any of the meetings?
20 A Yes.
21 Q Did anybody?
22 A Yes.
I 23 Q who?
24 A I don't recall specifically who attended.
25 .Q Can you separate out in your mind a first I
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1 Potts 198
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2 meeting, a second meeting, some kind of sequence 3 between the- meetings ?
4 A I can separate partially a sequence of
( 5 meetings.
6 Q Referring now to the first meeting, whenever 7 that one occurred, do you recall who was present at the 8 meeting from Babcock & Wilcox?
9 A The first meeting I recall was a B&W 10 meeting in Bethesda B&W offices. I rdcall Mr. Taylor 11 and Mr. Dunn and several licensees.
12 Q To the best of your recollection, only
(~)'
'~
13 Taylor and Dunn were there from B&W7 14 A Those are the two that I recall. They made 15 Part of the presentation.
, 16 Q Who else made part of the presentation?
17 A Well, they made the presentation.
18 Q Nobody else spoke?
19 A Not that I recall.
20 MR. KIRSCHBAUM: By speaking, you are
. 21 referring to speaking and the witness referred 1 .
22 to presentation. I am not sure the witness 23 understands.
((~'N,) 24 Q Did anyone else speak at all, like questions 25 and answers and that sort of_ thing?
-* - - - v- v- w- - e
1 Potts 199 2 A There were questions and answers, but part 3 of the presentation was Mr. Taylor made an introductory 4 and then Mr. Dunn made a technical presentation.
Was anybody present at this meeting from
{ 5 Q 6 any regulatory authority?
7 A Not at that meeting but later that day, 8 there was a meeting at NRC offices in Bethesda. The 9 first meeting was a meeting with the licensees in 10 Prep aration for the second meeting attthe NRC.
11 Q I take it these meetings occurred before 12 the accident?
13 A Yes.
14 Q What did Taylor say?
15 A That the analysis that Mr. Dunn or the 16 ECCS group in B&W had done, was available for 17 Presentation to the NRC and that the safe operation of 18 the B&W reactors would be demonstrated and that we were 19 in a good position for the presentation t' hat afternoon 20 at the NRC.
- 21. Q -What else did he say?
22 A I don't recall other comments.
23 ~ Q Did Mr. Taylor say anything about the HPI
. 24 system?
v 25 A Yes, the HPI system would require operator
1 Potts 200
/^1
\)
2 action to provide safe operation with the end that 3 the analysis demonstrated, that that would provide safe 4 operation.
(
- 5 I believe it was Mr. Dunn who defined the 6 specifics.
7 Q Do you recall the words that Mr. Taylor 8 used to discuss this matter?
9 A No.
10 MR. KIRSCHBAUM: You mean $he exact words?
11 MS. WAGNER: The exact words.
12 A No.
C\ ,
V 13 Q Did Mr. Taylor tell you what operator action 14 he was talking about?
15 A I'm not certain whether 'it was Mr. Taylor 16 or Mr. Dunn. I believe Mr. Dunn provided the specifics 17 of the presentation. .
18 Q Did Mr. Taylor say anything about the HPI 19 system from the point of view of hardware as op' posed 20 to operator action?
21 MR. KIRSCHBAUM: Are you asking if Mr. Taylor 22 discussed hardware of the HPI system? j t
23 MS. WAGNER: If he talked about the physical 24 system,-the pumps and whatever else goes into the 25 HPI system.
I 1
1~ Potts 201
[x 2 A I'm not certain on that point.
i 3 Q Did Mr. Taylor say anything about procedures 4 for the operation of HPI?
( 5 A Either Mr. Dunn or Mr. Taylor stated that 6 the procedures would require changes to define operator 7 action. -
8 Q You don't recall who said that?
9 A No.
10 Q Did you take any notes duri,ng that first l 11 meeting?
12 A I don't recall taking notes.
i '
a N 13 Q Do you know if anybody else from Metropolitan 14 Edison took notes?
15 A I don't know.
16 Q Can you recall anything else Mr. Taylor 17 said? .
18 MR. KIRSCHBAUM: Specifically?
19 - MS. WAGNER: Specifically.
20 A No.
. 21 Q Can you recall generally anything else 22 that he said?
23 A I can recall generally what the operator '
(n) sJ 24 actions were, but I believe that it was Mr. Dunn's 25 Presentation, as I said, that provided those specific ,
1 Potts 202
~
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2 details, not Mr. Taylor's.
3 Q Can you remember anything else that 4 Mr. Taylor said at all?
{ A No. '
5 6 Q Do you recall whether or not you understood 7 . what Mr. Taylor meant when he said that safe operation 8 of B&W reactors would be demonstrated?
9 A Chat operator action, when accomplished, 10 that the analysis that Mr. Dunn was about to present 11 provided the safety that the HPI system was designed to.
12 0 Is it correct that the issue that was being (N
13 addressed at this time was a specific small break which 14 was specifically defined?
15 MR. KIRSCHBAUM: The issue that was 16 being addressed --
17 MS. WAGNER: By this meeting.
18 MR. KIRSCHBAUM: I am not sure I understand i
what you mean by an issue being add'ressed by 19 a 20 meeting as opposed to an issue addressed by 21 somebody's presentation.
22 MS, WAGNER: I am talking.about why 23 everybody was there.
( 24 MR. KIRSCHBAUM: Why the. licensees came 25 to the meeting?
1 Potts 103 2 MS. WAGNER: Yes.
3 g Isn't it correct that the problem that was 4 being addressed was a specific small break which
( 5 involved, among other things, loss of oxide power and 6 a break at the discharge lines at the pumps?
7 A It involved the safe operation of the 8 plants and the break at the discharge of the pumps 9 was really a break in the main coolant piping.
10 Q Isn't it correct, however,1,that the 4
11 problem was a specific one that was being addressed 12 here?
O 13 MR. KIRSCHBAUM: Do you mean to exclude 14 anything else or are you talking about that 15 there was a specific problem and nothing else 16 was discussed at the meeting or are you trying 17 to -- .
18 MS. WAGNER: I am trying to ask what was 19 the purpose of the meeting.
20 MR. KIRSCHBAUM: From his standpoint?
91
~ MW. WAGNER: What did he understand
(_
33 everybody was there for.
23 MR. KIRSCHBAUM: I think he testified to
() 24 that, what he understood.
25 MS. WAGNER: Maybe I don't quite understand' l
1 Potts 204 (J.
2 it yet.
3 Q Was everybody there to discuss in~ general 4 whether or not HPI was a nice thing to have or had this
( 5 meeting come about because there was a specific problem 6 with the safety analysis for the HPI and the problem 7 was the small break problem which involved loss of oxide 8 power and a break at the discharge of the pump?
9 MR. KIRSCHBAUM: I object as to form because 10 you are posing two polar positioks that you are 11 presenting as being exclusive and they are far 12 from that.
/s ,
s
.V)-
13 MS. WAGNER: I would suggest those are two 14 ideas as to give me an idea what the question 15 is. You need not adopt either one as your 16 position.
17 12 Can you give me a description of what you 18 understood was the purpose of this meeting?
19 A I understood the purpose of the meeting was 20 to assure the licensees and, subsequently, in the 21 afternoon meeting, to demonstrate to the NRC that safe 22 operation was possible with -- that this analysis 23 demonstrated -- would be safe operation and it was not
?^
( 24 limited to a specific break size.
25 In fact, it included a number of break
1 Potts 205 d sizes.
2 3 Q Did y u understand that B&W was indicating
, 4 that the HPI system was functional if it was turned off?
(; 5 MR. KIRSCHBAUM: I object to the question 6 as to form. Are you referring -- are you asking 7 whether he thought that a piece of equipment would 8 work when it was off or the system would work?
9 MS. WAGNER: Whether that was one of the 10 things being addressed at this deeting, that 11 the HPI system, if it were disabled and turned
_s 12 off and nonfunctional, whether somehow that 13 would still work. ,
14 MR. KIRSCHBAUM: Disabled, nonfunctional 15 and turned off are all different things.
16 MS. WAGNER: Turned off.
17 MR. KIRSCHBAUM: As a result.of operator 18' action? -
19 MS. WAGNER: As a result of anything.
20 A Please repeat your question.
21 MS. WAGNER: Could you read it back, i
22 (Record was read back.)
23 Q Did you understand that B&W at this meeting i
( 24 was addressing the issue of whether or not the HPI system i
l 25 would function if it were turned off.by anybody?
, - ~ , , , .- - - . , , . , . -, . - -n. ,e , , . - g
1 Potts 206
(~h
~
\}
2 A No, My understanding was that if it was 3 operated with the instructions they were giving at that 4 meeting, that safe operation would ensue.
( 5 Q What did Mr. Dunn say at this meeting?
6 A Mr. Dunn =ade a presentation that included 7 overhead projections of graphs of the several sized 8 breaks that the analysis included, described generally 9 the location of the break and included the instructions 10 that the operator would need to operat'e the system.
11 MS. WAGNER: Could I have the answer read 12 back, please.
13 MR. KIRSCHBAUM: I would like the question 14 and the answer.
15 (Record was read back.) ,
4 16 Q What was the location of the break that 17 Mr. Dunn was discussing? -
18 A on the main coolant pipe lower elevation 19 between the pump -- the main coolant pump discharge and 1 l
20 the reactor.
21 Q When you say he included instructions for 22 system operation, what do you mean by that?
23 A He included several changes, several-steps rg !
( ; 24 that required changes to the emergency procedure.
25 Q Did he present to anybody at this meeting a
- - - ~ ~ - ~
1 I
}
l 1
I Potts 207
\s> -
2 procedure for operation of the HPI system?
3 A He included the steps of the procedure.
4 Did he include the steps of a procedure Q
( 5 applicable to the break he was discussing or did he 6 include a procedure which purported to cover entirely I the operation of HPI under any circumstances?
O MR. KIRSCHBAUM: Objection. Again the 9 implication of the question being those are the 10 only two possibilities that you are leaving open.
11 Q If he did anything else, tell me about that, 19 too.
f~~\ s 0 13 A He included in his presentation the 14 '
operator steps as changes to procedures.
15 Q Changes to another procedure?
16 A Changes to the emergency operating procedure, 17 Q Did you understand on which smergency 10 operating procedure the changes applied?
10 g y,,,
20 Which procedure was that?
Q
. 21 A The LOCA procedure.
22 Q Did Mr. Dunn present to the group a complete 23 LOCA procedure or just the changes that you have l
/~T
( ,) 24 described or something else?
l 25 MR. KIRSCHBAUM: Objection as to form.
l 1
1 Potts 208 r~ -
2 The witness may answer if he understands.
3 A He did not provide a complete procedure.
4 He provided changes, complete steps within that
( 5 Procedu're, if you will.
!' 6 Q Were those changes described by him as 7 intended to apply to the break, the range of breaks 8 that he was describing at this meeting?
9 MR. KIRSCHBAUM: Objection. Are you asking 10 him whether Mr. Dunn expre s s ed M'r . Dunn's 11 intention?
4 12 MS, WAGNER: Yes. I am asking if Mr. Dunn O 13 said whether or not these proced re changes he 14 was talking about were to apply to the range of 15 breaks and the types of breaks he was discussing.
?
16 A He provided those steps to provide for 17 continued safe operation of the HPI system.
18 Q Were those steps, as you understood it, 19 intended to apply to the break situation that he was 20 talking about at this time?
21 A They were intended to complete the analysis 22 necessary to make a safe HPI system.
23 Q Was there any connection in your mind, l 24 did you think there was any connection or did anyone 125 tell.you there was any connection, between the procedures
1 Potts 209 c.,
v( \
2 he was describing and the breaks he was describing?
3 MR. KIRSCHBAUM: Read the question back, 4 please.
( 5 (Record was read back.)
6 A The breaks he was describing were previously 7 unanalyzed which would bring us out of a safe operating 8 envelope. The steps and analysis provide our return g to that safe operating envelope.
10 Q The steps were i n t e n d e d t o'; a l l o w y o u to 11 return to the safe operating envelope if one of the 12 breaks described had occurred,-is that correct?
(g~h 13 MR. KIRSCHBAUM: I,nsofar as you are 14 attempting to characterize the witness' testimony, 15 I object. I object in addition because the 16 safe operating envelope that the witness referred 17 to before, I think it is being mischaracterized 18 as to whether or not if something happens, you-19 are in the safe operating envelope and if it 20 doesn't happen, you are outside of the envelope.
21 Q Do you understand the question, Mr. Potts?
22 A Not totally, no.
.23 MS. WAGNER: Read back the answer he gave 24 about the safe operating envelope which is about 25 three answers back, please.
, , _ , . n v n- --- w ~ +
1 Potts 210 p
()'
2 (Record was read back.)
3 Q Is it correct.that what he was telling 4 you was that in the event of one of the breaks he was 5 describing which would cause you to go outside of the
(
6 . safe operating envelope, if the steps he told you 7 about were used, you would be brought back into the
- 8. safe operating envelope?
9 MR. KIRSCHBAUM: Objection. I don't 10 believe you are correctly using the term as 11 the witness has used it.
12 The witness may answer the question.
r 13 A I believe he was-characterizing that in 14 addition to cther things.
15 Q What other things?
1G A I don't believe he characterized it as 17 limited to just that break. .
18 Q -What did he say about it?
19 A I don't recall his specific words.
20 Q Do you recall. generally what he said?
21 A Generally, the small break LOCA safe 22 analysis was done to provide safe operation of the 23 Plant under all of the range-of small break' sizes and
- 24 locations.
25 I believe that we were presented with a
- . _ . - -. , - I
1 Potts 211 7x .
U. 2 modification to that analysis or an additional analysis 3 that said if we followed these instructions, that the 4 Plant would then be operated safely and that the small breaks would not be an unsafe condition.
([ 5
. 6 Small breaks being whatever possible sizes 7 that were available or locations that were available.
8 Q Did Mr. Dunn say that if you followed the g steps he had just given you, a small break at any '
i l
10 location could safely be overcome by this HPI system?
I 11 MR. KIRSCHBAUM: Asked and answered. You l
12 have answered several times.
('T '
\_) You may answer it again.
13 14 THE WITNESS: Repeat the question.
15 (Record was read back.) ,
. 1 16 A Yes, those as a modification to the earlier 17 analysis, would now complete the small break analysis 18 so that safe operation was possible.
19 Q Just so the record is clear, my question 20 is, did Mr. Dunn address the issue of the location of 21 the break and did he say that at an'y location these 22 steps would provide safety?
23 MR. KIRSCHBAUM: Could you take that one
/~T *
(g 24 at a time.
25 Q Did he address the location, did he
I Potts 212
(_s -
2 specifically say something about the location?
3 A Yes. The location was important to describe 4 why_the original small break analysis had to be
( 5 modified or amplified.
6 Q Why was the location important?
7 MR. KIRSCHBAUM: Was important to Mr. Dunn 8
in his analysis?
9 Did Mr. Dunn say it was important?
Q 10 A Yes. -
11 Q Why did he say it was important?
12 A' The analysis was previously done with the Q 13 location of the break on the top of the pipe instead 14 of the lower level of the pipe and it resulted in 15 different conditions that had not been p.erceived.
16 Now they were perceived,and they had to be analyzed.
17 Q Was he talking, to the best kfyour 18 recollection, about a break in any location in the system 19 or was he talking about the difference of a break at 20 the top of the pipe and a break at the bottom of the 21 pipe 7 22 MR. KIRSCHBAUM: Objection because you are 23 seeming to exclude a middle ground.
/R, 24 'MS. WAGNER: He is talking about the. top 25 and the bottom of the pipe and I want to know
=-
w 1 Potts. 213
[~h 2 whether specifically Mr. Dunn said something i
3 specific about the location.
4 A We talked about the original analysis and
( 5 what some of the locations and sizes were in the original 6 analysis and defined why -- I don't recall the number, 7 but the number that was done in this additional analysis 8 and the location was different and why they resulted 9 in a different set of circumstances out of it.
10 Q What locations were addresh,ed by the new 11 analysis?
12 MR. KIRSCHBAUM: What do y u mean by n
'As 13 " addressed"? ,
[4 MS. WAGNER: Whatever the witness meant by 15 it.
16 MR. KIRSCHBAUM: Explain what you mean then.
17 A The additional locations that we talked 18 about in the meeting were that the original analysis 19 had'done a number of locations and that this new analysis 20 was of a different location than those -- an additional 21 location to those and additional sizes.
22 Q Which additional or different locations 23 were addressed by the new analysis?
24 A The one on the discharge side of the 25 main coolant pump at the lower side of the main cooling
1 Potts 214 t
2 P iP i ng.
3 Q Did Mr. Dunn address specifically in this 4 meeting any locations other than that one?
5 MR. KIRSCHBAUM: Again, I think there is 6 an ambiguity with the use of,the word " a d d re s s .'"
7 If you mean did he dis cuss specifically other 8 locations, that is one thing. If you talk about g addressing --
you are talking about what his 10 presentation was aimed at as o 9,osed to limiting 11 your questioning as to what was specifically said?
12 MS. WAGNER: I am asking what his words 13 were.
14 MR. KIRSCHBAUM: He has testified on 15 several occasions -- he has described the substance
) 16 on a number of occasions and I thibk you are 17 continuing to ask the same question at this point. ,
18 MS. WAGNER: I will try to g e't one answer 19 that I think is clear enough. '
20 Q Can you tell me whether Mr. Dunn i
21 specifically said anything about any location other 22 than the one that you described in your previous answer 23 which concerns a break at the lower part of the discharge
[] 34 line?
%d 25 A Yes.- ,
1 Potts 215 l
2 What other locations did he specificnlly Q s- ,
'3 address in his present$ tion?
4 Specifically addressed?
MR. KIRSCHBAUM:
5
{ Specifically discussed? .
6 MS. WAGNERr bhecifically talked about. ,,
J' ~
~, 7 .
7 A We specifically talked about at least on ' -
8 other break location' being til.'e suction side of the main 9 '
coolant pump. . -
,/, .
10 Q Did he say ar.ything about hny other specific
I .. . e **y 11 i
location? ,
12 A I don't recall their' specific loca'tions, 13 but we discussed in general the original analysis and I4 what it included which had other locations.
15 Q What else did Mr. Dunn say?
I0 MR. KIRSCHBAUM: Is your question addressed 17 to anything else that he might have said that 18 hasn't been covered somewhere along the line 10 of this testimony? ,
20 MS. WAGNER: Yes, if he can recall.
/
- ~ ~
21 A I'm not certain whether.we a"r e t a lking -
~~
about the meeting in B&W's office or NRC's o f fi'ce .
23
, Q The first meeting in B&W's ffice.
- O
(/
e
~4 A That is all I can remember.
2a_
- g. Do you recall whether or not he said J
r* m
.:9
- . , - . . , , , , . , - - . . - . . , , -, ,., w..n. - ., - - - - - -
r ..n, -
. - . n. .. . - _ ~ . ._
.1 Potts 216 1
~
2 anything other than what you have previously testified 3' to concerning procedures for the operation of HPI?
4 A No.
Q Do you recall whether he said anything
( 5 6 other than what you have already testified to concerning 7 hardware aspects of the HPI system as opposed to 8 Procedures for its operation?
9 A Hardware aspects were part of that meeting.
10 g I believe Mr. Dunn was part of that discussion.
11 Q What was discussed?
12 A There would be a long-term small break
('
13 fix to prevent the less of electric po er or the loss l
4 14 of a single HPI pump which, when that hardware fix j 15. was installed, would remove the necessity for the 16 operator actions that we were describing.
i 17 Q What was that fix to be? ,
18 A At that time there were seveial possibilities 19 that had yet to be designed and analyzed.'
20 Q Was-that to be part of the presentation 21 to the NRC later in the day, the hardware fix?
22 A It was a minor part of the discussion with 23 the NRC.
t MS. WAGNER: Why don't we have a break now.
f]h x 24 4
25 (Recess taken.)
4
s.
1 ";
s 1 Potts 217
_(n - ~
b 'BY MS. WAGNER: '
2
\7 3 Q Mr. Potts, just to clarify the testimony 3 -
4 that we have just had, when you were speaking about (1 5 what Mr. Dunn said about loedtion of breaks, did your 6 answers concern the entire meeting, whether the issue 7 under discussion at that time was hardware or software?
s .
, 8 MR. KIRSCHBAUM: I don't underutand the k
g , qkestion. .
10 x Q Toward the e d of your tashinony, you 11 discussed what Mr. Dunn 'had sdid about a hardware fix 12 in this situation and my question is only whether or not 13 when ycu were responding to my questions about what 14 Mr. Dunn said about location, whether you w'ere excluding 15 for any reason that part of the meeting during which w -
t .g
- 16 he was discussing this,,hardwase fix?
17 MR. KIRSCHBAUM: I am still not sure I 18 understand the question.
T .
19 You can answer if you unders'tand it.
20 A The purpose,of;the hardware fix was to N
21 remove the necessity for $he operator action and it
{ (%
22 would come at a subsequent date.
23 Q During the time when Mr. Dunn was talking
~
[)
N_/ 24 about that, did he siy anything in addition ~to what you-25 :have testified about,'alreddy concerning Che' location of s -
_ , , , . . ~ - . . - -
l 1 Potts 218
/~3 '
2 breaks?
3 A No.
4 Q After this meeting I believe you testified 5 there was a subsequent meeting at the NRC, is that
(( ,
6 correct?
7 A Yes.
8 Q Who attended that meeting from Babcock &
9 Wilcox?
10 A There may have been others in addition to 11 Mr. Taylor and Mr. Dunn, but the presentations were 12 made by them. Those are who I recall.
_) 13 Q Who else attended the meet'ing, if anyone, i
14 from Met Ed or CPU?
15 A I don't recall the attendance list, who 16 attended.
17 Q Do you recall who attended on behalf of
~
18 the NRC7 10 A There were a number of NRC individuals 20 Present. I don't recall their names.
21 Q You don't recall any names?
L 22 A No.
23 Q What was said by Mr. Taylor at that meeting?
j 24 A Mr. Taylor again provided the introduction 25 to the meeting, that the purpose of the meeting was to
,, . ---e., , , . - , ,. , - - - - -, -.
1 Potts 219
(
(_) 2 demonstrate the safe operation of B&W licensees for 3
small break analysis and Mr. Dunn would make technical 4 presentation and technical presentation would be f 11 wed by a peri d f questions and answers for the
{ 5 6 NRC's benefit, provide an agenda of the meeting, if 7 you will.
8 Q Did Mr. Taylor say anything at that time 9 or at any time during this meeting concerning the 10 HPI system? g 11 A The HPI system, yes.
12 Q What did he say?
13 A The HPI system would require operator action 14 to provid'e safe operation"for the plants' .
15 Q Did he describe the operator action?
16 A Yes.
l 17 Q What did he say about it?
18 A The operator action would include the 19 steps on initiation" of'HPI, the operator would observe 20 his flow indicators. If flow was found on all four 21 indicators and he had electrical power to both 22 electrical buses, no further operator action.
23 If,in the other case, the flow was missing
(' 24 on two of the indicators or we did not have electric
\_.
25 power to the one emergency bus, the operator would be
1 Potts 220 2 required to open the HPI cross-connect valve and 3 then balance the flow through the four flow indicators.
4 Q Did he say anything else about operator 4
{ 5 action?
l 6 A The time of operator action was a matter -
7 of discussion, I believe, as a result of the questions 8 from the NRC.
9 Q Did he say anything about the HPI system 10 frca a hardware point of view? e 11 A I'm not sure if Mr. Taylor said anything 12 about the hardware.
13 Q Did Mr. Taylor say anything about the 14 safety analysis for the HPI system?
- 15 A Yes, the NRC would be presented with the 16 additional analysis at that meeting. They were 17 presented with the additional analysis. _
i 18 Q He didn't say anything substa'ntive?
19 A That was the purpose of Mr. Dunn's 20 technical presentation, to describe the analysis.
21 MR. KIRSCHBAUM: I object to the use of 22
- the word " substantive" in that question. I i
23 don't know if there is an implication that the
. 24 witness testified Mr. Taylor's presentation is 1
25 not in any way substantive.
1 Potts 221 2 Q Did Mr. Taylor,say anything about any 3
LOCA procedure?
4 A That the operator action that was required 5 would be-required to modify the emergency procedures.
(
6 Q Did he say anything about the,LOCA emergency 7 Procedures other than that?
8 A No.
9 Q Do you recall anything else Mr. Taylor 10 said at this meeting?
11 A No.
12 Q Do you recall whether or not Mr. Taylor 13 ~ responded to questions at any time during the meeting?
14 A Following Mr. Dunn's presentation, there 15 were a number of questions from the NRC. The response 16 was from various parties of B&W. ~
17 Q Do you recall whether or not Mr. Taylor 18 said anything at that time? -
19 A I'm not certain he answered those questions.
20 Q Were only Mr. Taylor and Mr. Dunn making 21 Presentations at this meeting?
22 A Those are the two that I recall making 23 Presentations.
24 Q What did Mr. Dunn say?
25 A Mr. Dunn described the analysis, described
1 1 Potts 222
. -f g s +
\-) 2 why safe operation was assured, described the scope 3 f the breaks and responded to a number of questions 4 from the NRC.
Q What did Mr. Dunn say about the analysis?
{ 5 6 A That with the operator action, it provided 7 for the safe operation of the B&W licensees since other 8 licensees were involved.
g Q Did he say anything else at all about the 10 analysis?
11 A Other than responding to the questions?
12 MR. KIRSCHBAUM: Other than the description 13 that the witness mentioned befor'e?
14 MS. WAGNER: I am asking what the 15 description was. I thought he was responding 16 to that.
17 MR. KIRSCHBAUM: You asked him before what 18 was said and he said Mr. Dunn descr'ibed the 19 analysis and then you didn't ask him for the 20 description. You asked him something else.
21 MS. WAGNER: I am asking what Mr. Dunn 22 said about the analysis. I thought that would 23 have included a description of the analysis.
24 Q If it didn't, could you tell me.what the 25 description of the. analysis was?
7, ,
1 Potts 223 f's
- 2 .A Mr. Dunn provided a description of which 3 computer codes were used. There were several' slides 4 or overhead projections that were used as a part of f
( -
that.
5 6 Q Were those the same ones that were used in 7 the morning?
8 A Yes.
9 Q What else did he'say in describing the 10 analysis? '
t 11 A The description he provided the NRC was 12 very similar to the description he had provided us
(- 13 earlier in the meeting, other than there were additional i
14 questions asked by the NRC. '
15 Q Can you tell me now what it was that he i 16 said to the NRC? 1 i
17 MR. KIRSCHBAUM: In response,to the
~
18 additional questions?
19 MS. WAGNER: In describing the analysis.
~ '
l l
20 MR. KIRSCHBAUM: Including the things that )
21 were said previously?
, 22 MS. WAGNER: I want to know what was said 23 to the NRC in describing the; analysis, whether 25 licensees.
1 Potts 224
.O k- 2 A I don't recall anything in addition to 3 what was provided to us in the morning other than the 4 NRC questions and answers.
5 Q What do you recall about the NRC questions
(
6 and answers?
7 A The NRC probed the analysis to assure 8 themselves that the analysis was complete and that 9 its action --
in addition to the earlier small break 10 analysis, now provided safe operation.
11 Q How did the NRC probe the analysis?
12 A They asked questions about a number of
( 13 different break sizes and locations t[ assure if the 14 correct sizes and locations had now been analyzed.
15 They asked questions about the amount --
16 the length of time required for the oper$ tor action to 17 open a cross-connect, the amount of time required for 18 the operator to recognize his flow indications, the 19 electrical indications. -
20 Late in the meeting, the subject of the 21 hardware fix came'up as questions from the NRC and what L 22 would be the schedule analysis by B&W and the several 23 licensees involved in that meeting, what time frame r'N 24 would we provide B&W's analysis to the NRC for the
\/
25 hardware fix.
y Potts 225 w/- 2 Q Was B&W's analysis for the hardware fix different from B&W's analysis for the software fix?
A Yes. It would be different. It had not 4
been completed as yet. -
6 Q Did Mr. Dunn say anything in his presentation concerning the hardware fix?
7 g A B&W answered the questions about the g
analysis. I don't'know if it was Mr. Dunn.
10 Q I maan during Mr. Dunn's p esentation, do g you recall whether --
73 MR. KIRSCHBAUM: As opposed to the questions 13 and answers?
74 MS. WAGNER: Yes.
A I. don't recall that being part of the 5
presentation.
16 y7 Q Do you recall during the question and answer 18 session what Mr. Dunn said concerning break sizes?
yg A .He described the spectrum of break sizes a a een ana Yze as mPlete when they were added
- 20 g to the original small break analysis spectrum.
g Q- Are those the words that he used?
A That is a. paraphrase or my recollection of 23 p what he said.
V Q What did he say about the break locations?
)
1 Potts 226 "N ~
'" A Here again it was described that the break 2
3 1 cation on the discharge side of the main coolant pump 4 was different'from the break location on the suction 5 side of the main coolant pump.
6 Q Again, are those the words that he used?
7 A That is a paraphrase of his presentation.
8 Q Do you remember anything more about the g words that h'e used?
10 A Specific words, no. g 11 Q Do you remember if he said anything else 12 about any other break location?
13 MR. KIRSCHBAUM: Any other specific break 14 location? I 15 MS. WAGNER: Yes.
16 A I don't recall specific locations that were 17 discussed.
18 Q Do you recall if Mr. Dunn said anything 19 else either during his presentation or any'other time ,
20 concerning the operation of the HPI system?
21 MR. KIRSCHBAUM: Read it back, please.
L 22 (Record was read back.)
23 MS. WAGNER: At any other time during this
~'s meeting is what
[d 24 I mean, 25 A He described the operator actions that would w- p. .,w---- , y- , - - , , * -+, 1--av-=-
1 1 Potts 227
. s.
'- 2 be necessary to make the safe operation with this 3
analysis, the same as the description I had given 4 you earlier, those several steps.
5 Q Do you recall whether Mr. Dunn discussed g{
6 in this meeting, at any time during the meeting, any 7 LOCA procedure other than the steps that you have g previously described that were to be added to the LOCA 9 procedure?
10 A No, they were not discussed.
11 Q What else did Mr. Dunn say about the 12 ~ operation of the HPI system, if anything, other than
, 13 what you have testified to?
g4 A I don't recall other than what I have 15 described.
16 Q Did you take notes at this m'eeting?
17 A I don't recall taking notes at this 18 meeting. -
10 Q Do you know if anybody else at Metropolitan 20 Edison or GPU took notes at the meeting /
21 A I don't.
22 Q Do you know why it was that you were l
23 attending these. meetings?
24 A I was the supervisor of Licensing at that f'
V 25 time.
1
)
l
1 Potts 228
,e m 2 Q This was a licensing issue?
3 A Yes, it was.
4 How was it a licensing issue?
Q 5 A B&W had reported it as a Part 21 issue.
({
6 Q Do you recall any other meetings other than 7 these two concerning the small break' problem that we
'8 have bocn discussing at which Mr. Dunn or Mr. Taylor 9 or anyone else from B&W were present?
10 A Yes. 1 11 How many other meetings?
Q 12 A I don't know the number.
k- 13 ,Q Do you know vaguely what the number 1s?
14 Is it more than five?
15 A I wasoat, subsequent to these meetings, e
i 16 at Lynchburg on the small break LOCA.
17 Q Do you recall how many times.you were at 18' Lynchburg?
19 A No.
20 MR. KIRSCHBAUM: On this subject?
l 4
-21 MS. WAGNER: All my questions have to do L -22 with this basic subject now.
23 Q Can you separate in your mind the meetings
-(Oj 24 in some sequence, a first meeting , a second meeting, 25 that sort of thing?
S
,,_y_. 7- ___._,_...,.w. 4, _
I 1 .Potts 229 f\
d' 2 A No.
3 Q .can you' recall who, if anybody, attended 4 the meetings besides you from Metropolitan Edison or 5 General Public Utilities?
(
6 A No.
l 7 Q Did you take notes at any of the meetings?
8 A I don't recall taking notes.
9 Q Do you know if anybody else from '
! 10 Metropolitsn Ediscn or GPU took notes?g l 11 A No.
12 Q Do you recall whether or not Taylor or Dunn 13 attended any of these meetings?
I 14 A I recall a meeting at Lynchburg where 15 Mr. Taylor and Mr. Dunn were present.
16 Q Do you recall any other meet ng at which 17 they were present? ,
18 MR. KIRSCHBAUM: In Lynchburg'?
, 19 MS. WAGNER: In Lynchburg about this subject. ,
20 A No.
21 Q They were both present at this meeting 22 that you recall? ,
l- 23 A Yes.
/~N 24- Q Do you recall who else was present from
! any place?-
25 l
k
- - - - - . , . , - - , . - _ . - . , . ,._ . . . . - - , . - ~ , . _ _ , . _ , , - . . - - - ....._ -. ._, -
i 1- Potts 230 4
- 2. A Y( s .
J 3 Q Who else was present?
I
.4 A I recall Mr. Jania being present.
4 5 Q Who is Mr. Janis?
j
{
i 6 A A B&W employee.
i
! 7 Q Do you recall anybody else?
i~
8 A No.
i 9 Q Do you recall whether any other customers i 10 were present? g 4 .
i 11 A Yes.
12 Q I mean customers of Babcock & Wilcox.
4 13 A Yes.
~
I I- 14 Q Do you recall who they were?l 15 A Yes.
t 16 Q Who were they?
i i 17 A I recall one individual.
i 18 Q Who is that?
19 A Mr. Raasch from Sacramento.
- 3 20 Q Do you recall whether or not other people 21 were present regardless of whether you remember who i 22 they were?
i 23 A Yes.
- . 24 Q Were there other people present?
25 A Yes.
.._.6, c ,-- = , - , - , p., e ,w.-,y, .,r+m., - r. ,,,. ,,,,,3.-.m w q ._ ,_,y-,w y-y-m-, _.p.e m e ,,-..--,y.,99,oefmwy,..mm-v.m.,9%m-w-my%= -ww
- 1 Potts 231
(~J~
) ~
~
2 Q Do you recall whether they were also 3 customers o.f B&W or whether they were from some other 4 place like the NRC or B&W7 5 A I recall that there were additional
{
6 licensees or customers of B&W present.
7 Q Do you know what the purpose of this j 8 meeting was?
j g MR. KIRSCHBAUM: Objection. Does he know 10 his purpose in being there or th,e purcose of the -
11 meeting being called by B&d?
12 MS. WAGNER: Does he know the purpose of
- i 13 I the meeting.
4 .
j 14 A Yes.
15 Q What was the purpose?
16 A The purpose of the meeting was to discuss 17 scheduling and the progress made of the hardware fix
~
18 analysis.
19 Q Did this meeting occur after the two
- 20 meetings that you have described previously this 21 morning?
,22 A Yes.
23 Q Did Mr. Taylor or Mr. Dunn say anytning
[') 24 at this meeting?
%J 25 MR. KIRSCHBAUM: All your questions are
1 Potts 232 1 -~
s )- 2 ,
aimed at the meeting that the witness testified 3 that he recalls Taylor and Dunn being present 4 to the exclusion of any other meetings?
5 MS. WAGNER: That's correct.
(
6 A Yes.
7 Q Did they each say something?
8 A No.
) 9 Q Who said something?
10 A Mr. Dunn was asked a quest on about the 11 hardware fix and how it would interact with the 12 analysis.
Was there any presentation ma,de at thia 13 Q
~
14 meeting? l 15 A Yes.
16 Q Who made the presentation or presentations?
17 A I don't recall. .
~
~
18 Q Do you recall wheth~er it was personnel from 19 B&W or from licensees? -
20 A Yes.
21 Q Which one?
22 A It was B&W.
23 Q What were the presentations about?
A There were some figures given on cost (T 24 L.)
25 of the analysis to date and projected cost'and several y . .. - .-- .,-..,% 3 y-. -
m we- _- ,-v y e g
l 1 Potts 233
-O
- 2 phase breakdown of the analysis sequence or the hardware 3 fix sequence.
4 Q Is the analysis you have just discussed 5 the analysis having to do with the hardware fix?
({
6 A . The analysis I answered in my last answer 7 had to do with the hardware fix.
8 Q What was said at this meeting by B&W
, 9 personnel other than Taylor and Dunn about the HPI 10 system? g 11 MR. KIRSCHBAUM: Are you asking the witness 12 if he can recall specifically something that was
'(
13 said by Taylor and Dunn? If th$ s~ame thing 14 said by Taylor and Dunn was said by someone else, 15 is that included in the question?
16 MS. WAGNER: I want to hear t if it was 17 said by someone else, even if it was said by
~
18 Taylor and Dunn.
19 THE WITNESS: Repeat the question.
l 20 (Record was read back.)
21 A The most probable fix for the small break
(~ 22 LOCA problem would be a hardware fix involving 23 cross-connect piping between the discharge lines of I
(~N 24 the HPI pumps.
\- l 25 Q Do you recall who said that? l 1
l l
i._
- 1. Potts 234
(, -
'k 2 A No.
3 Q .Do you recall whether anything was said in 4 that connection concerning break location?
- ~
5 A No.
6 -
Q You don't recall one way or the other?
7 A I don't recall one way or the other.
8 Q What did Taylor say at this meeting, if 9 anything?
10 i A I don't recal3 what else M,r. Taylor said.
i 11 Q What did Mr. Dunn say at this meeting, if 12 anything?
13 MR. KIRSCHBAUd: He already testified 34 that Dunn said some things. You mean other than 15 what he said Dunn said?
1G Q What did he say other than what you have 17 testified to?
18 A The installation of the cross'-connect 19 P i ping would remove the necessity for the' operator 20 action.
21 Q Did he say anything else?
L 22 A I don't recall him saying anything else.
23 Q Did anybody at this meeting say anything
['/
\._
h 24 about the safety analysis for the HPI system?
A Yes.
25
v 1 Potts 235 2 Q What was said?
3 A A discussion of how the analysis that had 4 previously been performed and was presented to the NRC 5 in that meeting we discussed and this follow-up analysis
(
6 for the hardware fix and how it wculd be paid was 7 discussed.
8 Q Was anything discussed about the analysis 9 other than that, other than how it was to be paid for?
l 10 A I don't recall other things being discussed.
1 11 ! Q Did anycne at this meeting say anything
/*
12 about the energency LOCA procedure or any emergency
/ 13 LOCA procedure other than what you have testified to 14 which is that operator action wouldn't be needed once 15 the hardware fix came into being?
16 A That is what I recall of the discussion.
17 Q You don't recall anything else?
18 A No.
19 Q Do you recall anything else being said at 20 this meeting by anybody concerning the LOCA procedure?
21 MR. KIRSCHBAUM: Are you referring to a 22 specific LOCA procedure or is that a small "p" 23 or capital "P"?
24 MS. WAGUER:
[ ))
L Any LOCA procedure.
25 MR. KIRSCHBAUM: Any procedure in connection l
l
1 Potts 236
/"'N '
N- -
with LOCA, I take it?
, 2 3
MS. WAGNER: Yes.
4 A Other than the discussions of how we would i Pay for the procedure.
( 5 6 Q Do you recall any other meetings any place 7 but with B&W concerning this issue, the whole small 8 break issue?
o A No.
i 10 lI Q Do you recall when this me,cting was that 11 you have just described, generally?
12 A 7es.
13 Q when was it?
II 14 A It was' subsequent to the meehing with the 15 NRC.
16 Q Other than that, can you place it in time?
17 MR. KIRSCHBAUM: Exactly, approximately?
18 MS. WAGNER: Approximately or' exactly.
19 A ' Wit'hin a few weeks is the best that I can 20 P l ace it.
21 Q Within a few weeks from the NRC meeting?
22 A NRC meeting.
23 Q You can't place it within a year or within
(~T 94 some month in a year or anything like that?
v) -
25 A I cann t place it within a month. It was
- - - - - , e r e y
1 Potts 237 h)
L,/ - within that year when the meeting with the NRC 2
3 ccurred.
4 Q Do you know what year that was?
5 A It was 1978.
6 Q I would like to go back now briefly to 7 the meeting at the NRC, the second meeting we have 8 discussed today.
9 You indicated that Burt Dunn said a number 10 of things at the meeting, one of which was why safe 11 l Operation of the HPI was assurad given the operator
[
12 acticn he was at that time describing.
l 13 Can you renember anything 'else that he said i ,
14 about why safe operation was assured?
15 MR. KIRSCHBAUM: I object to the. question.
^
16 You have taken part of the witness' testimony and 17 now you are asking whether he can recall anything 18 else. He testified to a number of -things that 19 Burt Dunn said at the meeting and I-really 1
20 think unless you want him to repeat everything I l
21 that he recalls Dunn having said at the meeting 22 again, the question is unfair. If you want him 23 to repeat everything Dunn said, the question was i j l
asked and answered.
/]
%. /
24 1
25 Q I would like to know whether Burt Dunn
l 1 Potts 238 2' said " Safe operation is assured."
3 MR. KIRSCHBAUM: Quote?
4 MS. WAGNER: Quote.
5 A I'm not certain he said the word " assured."
[
6 Safe operation of the plant was the purpose of the 7 meeting and it was the purpose of his discussion with 8 us, to assure us and then subsequently assure the NRC 9
I of the. safe operation.
10 } Q Do you recall other than what you have 11 already testified to this morning, whether or not he 12 j said anything to q'ualify or give more detail to the
~
g statement that safe operaticn is assur'ed or whatever 14 statement he made that gave you the impression that 15 is what he meant?
16 MR. KIRSCHBAUM: Read that back, please.
17 (Record was read back.) -
18 MR. KIRSCHBAUM: I object to'the question 19 as to form. The witness may answer; 20 A I don't recall him qualifying his statement 21 with other details other than what lt have given you.
22 Q Do you know if any other meetings were 23 held concerning this issue, held between B&W customers,
~} 24 including Metropolitan Edison, which you did not attend?
uj 25 A I don't know.
1 Potts 239
(
2 Q You do not know of any or you do not knew 3 ne way or the other?
4 A I don't know if there were.
( 5 Q Did you ever hear of any such meeting?
6 MR. KIRSCHBAUM: That he did not attend?
7 MS. WAGNER: Yes.
8 A I don't recall hearing of meetings --
9 Q Do you know scmebody --
10 A --
that I did not attend. t 11 Q Do you know somebody called R. C. Cutler?
l 12 A Yes. 1
.O 13 Q Who is R. C. Cutler?
14 A Mr. Cutler is an engineer for GPU Service 15 Corporation.
16 Q Did he attend any of the meetings that you 17 have described with you?
18 A I don't know if Mr. Cutler did or not.
19 Q Did you and Mr. Cutler ever discuss any 20 of these meetings?
21 A I don't recall discussing them with- s 22 Mr. Cutler, i
23 Q Did you discuss.these meetings with anybody
()
s_-
24 before the accident?
25 A Be' fore the accident, yes.
1
1 Potts 240 y S. -
2 Q With whom?
3 A The Vice President of Generation.
4 Q Who was that?
5 A Mr. Herbein.
{
6 Q What did you talk about with Mr. Herbein?
7 A The safety implications, the scheduling 8 implicaticns, the impact on Three Mile Island Units 1 9 and 2, costs.
10 . Q What did you say about the safety 11 implications?
i 12 A That the safety analysis that BaW presented
^
13 tc the NEC cssured the safe operation of TMI.
I 14 Q Did you ever read the safety. analysis shat' 15 was presented?
16 MR. KIRSCHBAUM: At which meeting?
17 MS. WAGNER: The safety analysis that 18 concerned the operator action, whenever it was 19 Presented. -
20 MR. KIRSCHBAUM: There may have been more 21 than one analysis. That is why I am trying to
.22 get a qualification.
23 Q Was there more than one?
24 A I don't-recall.
(V~)
25 Q Do you recall any analysis?
-. _~ , -,., _
1 Potts 241 2 A I don't recall if I had the analysis or 3 n t. There was an analysis that was presented to the 4 NRC.
( 5 Q You do not recall whether you reviewed that 6 analysis yourself?
7 A That's true.
8 Q Have you ever reviewed a safety analysis 9 such as that?
10 MR. KIRSCHEAUM: At any ti e7 11 MS. WAGNER: At any time.
i 12 ' MR. EIRSCHBAUM: Any safety analysis?
O- 13 l MS. WAGNER:
~
Before the accident.
14 MR. KIRSCHBAUM: Any time before the 15 accident, any safety analysis of any kind?
16 MS. WAGNER: Yes.
17 A Yes.
18 Q Have you reviewed many such a'nalyses?
19 A No. -
20, Q How many would you say?
21 A I would characterize it as 10 to 20.
L 22 Q What was your position when you reviewed 23 .such safety analyses?
24 MR. KIRSCHBAUM: Pre-accident?
25 MS. WAGNER: Pre-accident.
e
1 Potts 242
}
^ A Supervisor of Licensing.
2 3 Q Did these analyses concern the operation 4 of a nuclear power plant?
( 5 6
A Q
Yes.
Did they involve different> pieces of 7 equipment? ,
8 A Yes.
I g Q Did they involve different procedures?
10 l A 'l e s . g 11 Q When you reviewed them, what was your I .
12 Purpose in reviewing them?
13 MR. KIRSCHBAUM: All of tIem, some of 14 them? .'
15 MS. WAGNER: All of them.
1G Q . Was there any practice that you had with 17 respect to reviewing safety analyses?
18 MR. KIRSCHBAUM: Practice in" terms of 19 Purpose?
20 ,
MS. WAGNER: In terms of purpose.
21 A Safety analyses were occasionally' submitted 22 to the NRC as attachments to licensing documents and 23 in those cases, I did review them.
l i 24 Q What were you reviewing them for?
(\_/
25 MR.-KIRSCHBAUM: Objection as to form.
, 4 , . - - ym - . . , . _- r - , + . . . . - .
1 Potts 243
[^T '
2 A I was reviewing them to insure that the 3 attachment was complete, that it met the request of 4 the NRC,if they had requested it, or if it was a reload 5 report or something that we normally submitted to them
((
6 without a request, that it met the NRC's requirements 7 for those kinds of submittals.
~
8 Q Did you review safety analyses for g subs'tance?
10 , A I did not provide the techpical review of i I '
11 '
aatety analysea, if that is responsive to your question.
l l 12 Q I believe that is what ny question vac, yes. )
13 Who did, if anyLcdy at Metropclitan Edison, 14 provide such review? You can tell me a department 15 rather than a person.
16 MR. KIRSCHBAUM: While he was supervisor?
17 MS. WAGNER: Yes.
18 A Those safety analyses reviewe'd by Met Ed
^
19 would have been reviewed by the Engineerihg Department.
20 Q When you attended the meeting at which the 21 safety analysis for this small break LOCA was discussed L 22 and presented, did you understand it?
23 MR. KIRSCHBAUM: Read the question back, 24 Please.
25 (Record was read back.')
1 Potts 244 f%
% MR. KIRSCHBAUM: Are you referring to 2
3 one meeting or one of the specific meetings?
4 MS. WAGNER: I am referring to the B&W
( 5 6
analysis. It is not clear to me whether Mr. Potts over physically had it. Whatever he knew about 7 it from whatever source, did he understand it.
4 8 MR. KIRSCHBAUM: You are talking about the g written document only?
10 MS. WAGNER: I am talking,about the written 11 document or any oral review of that document 12 which he heard.
13 MR. KIRSCHBAUM: And you Are asking whether 14 he understood any, all or some of it?
15 MS. WAGNER: Whether he understood the 16 analysis.
17 MR. KIRSCHBAUM: You don't want to qualify 18 it further in terms of any, all or'some?
19 MS. WAGNER: No. '
20 MR. KIRSCHBAUM: Objection as to form.
21 You can answer.
22 A Can you restate it?
23 Q Do you know what I am referring to when I 24 talk about the small break analysis that we have been 25 discussing all morning?
, T h 1 Potts 245 :
p '
( 2 A , Es -
3 ,.. 3 3 6
3 Q~ 'Did y u understand that before the
~
g 4 accident 7;
- 5 14R. KIRSCHBAUM: Objection as to form.
C \
6 A I had some understanding of that analysis 7 before the asci' dent. .
k \
s 8
8 Q Was'your undersCanding based upon what you
'n 9 heard in these meetings or was it'hased upon any other
( 10 review? g .,
s 11 A Based on primarily the understanding I
's e 12 ga'ined,in the meeting.
n i, s' s e- ,. r, ,
-' [
V' .
13 , ,
Q- so you know if anybody at Metropolitan Edison, any eng'ineer reviewed or the Engineering 14 15 D ep'a': t m e n t reviewed the saf ety analysis'?
a 16 A I don't recall specifically.'
17 ,.
Q Did you discuss that with any engineer, 18 the; safety analysis?
, 19 1 A Otiher than a Licensing engineer?
x 20 Q Including a Licensing engineer.
21 A I don't recall specifica1'ly discussions 'of 22 that with other engineers.
23 Q Do you recall generally whether you had r% 24 such a discussion?
b, 25 A Other than it would be normal to discuss F i
? r .-
~
a .s h.___
7 ,
I 1 Potts 246 2 it with a Licensing engineer.
3 Q Would it be normal to discuss the substance 4 of the safety analysis with the Licensing engineer?
5 MR. KIRSCHBAUM: What do you mean by
{'
6 " substance"?
7 Q The technical aspects as opposed to the 8 format, Mr. Potts.
9 MR. KIRSCHBAUM: I am not sure I agree there 10 is only again a technical aspect t and format.
11 Q Did you discuss the technical aspect with 12 the Licensing engineer or would it have been normal to 13 do-Eo?
14 A It would have been normal to discuss the 15 technical aspects.
16 Q Did anybody in the Licensing Department 17 at that time have the qualifications to understand 18 the safety analysis? ~
19 MR. KIRSCHBAUM: If the witness had an 20 opinion at that time as to the qualfiications 21 of the other people in the department?
22 MS. WAGNER: Yes.
23 A A certain understanding of that safety I
34 analysis'would have been within the qualifications 25 of the Licensing engineer.
Potts 247 l l
A Q Not a complete understanding?
A The analysis involved computer codes such as FOAM and THETA and those things and I didn't have an understanding of those computer codes nor do I believe 6
the Licensing engineer had an understanding of those computer codes.
8 Q Other than the computer codes, do you i belicve you had the qualification to comprehend the rest g of the analysis other than how the com uter codes worked?
g A Computer codes are an essential part of g that analysis. An understanding of thst analysis wouldn't be within my capabilities.
la.
MR. KIRSCHBAUM: We are referring to the analysis which contained those code's?
6 MS. WAGNER: That's correct.
18 Q Did you ever come to hold the opinion that gg B&W's high pressure injection system was not safe to operate?
MR. KIRSCHBAUM: Pre or post-accident?
MS. WAGNER: Pre or post-accident.
A Before the accident, I had the understanding that it was safe. Subsequent to the accident, that 24 J-
- opinion changed.
i
1 Potts 248 O 2 Q What was your opinion subsequent to the J
3 accident?
4 A Subsequent to the accident, there were
( 5 additional instructions necessary to operate safely.
6 Q What was your change of opinion based upon?
7 A Based upon reading in the Kemeny Commission 8 report and the Rogovin report that there were additional 9 instructions resulting from the Davis-Besse incident 10 that were necessary to the LOCA procedure.
11 Q Is it correct that your change in opinion 12 was not based on anything new you discovered about the k- 13 hardware of the HPI system, but it had to do with the p 14 procedures for its operation?
15 A I don't recall the hardware being discussed.
16 It was the procedure steps that were within those 17 reports.
3 18 Q And it is the procedure stepi which
- 9
. resulted in your change of opinion, is that correct?
20 A That's correct.
21 Q Did you have an understanding prior to the L 22 accident that if a small break LOCA occurred and the HPI 23 _ system were shut off, that the nuclear steam supply 24 system would be protected from damage?
[G) 25 MR. KIRSCHBAUM: Is your question referring
)
l l
Potts 249
- 1 (O_) to the HPI system being shut off at any particular point in time?
3 MS. WAGNER: During the incident or within five minutes after its initiation. Let's take 5
C it throughout the incident.
6 Q Suppose there was no HPI operatable and a small break LOCA occurred.
8 MR. KIRSCHBAUM: Then what?
9 Q Was it your understanding that the system 10 g would be protected from damage?
MR. KIRSCHBAUM: The system being what?
MS. WAGNER: The nuclear steam supply
, system.
MR. KIRSCHBAUM: It would be protected from damage in all cases if a small break LOCA occurred and the HPI were unavailable?
17 MS. WAGNER: Right. .
A It was my understanding pre-accident that only one train was necessary to be available for small break LOCA.
21
(' Q What if you didn't have any train at all,
'did you have an opinion as to whether or not a small
-break LOCA in the nuclear steam supply system would be protected from damage under those circumstances?
25
1 Potts 250
(~% ~
(-) 2 A The understanding I had was everything we 3 had done was to insure that one HPI system would be 4 available.
5 Q Did you give any thought at all to the 6 possibility that all HPI could be, for_some reason, .
7 unavailable?
8 MR. KIRSCHBAUM: Pre-accident whether he 9 actually gave thought to this possibility we are ,
10 discussing?
t.
11 MS. WAGNER: That's right.
12 A I gave thought to it. Pre-accident, it
() 13 was not a possibility to lose both trains.
~
14 Q During the meetings that you,'have discussed, 15 did anybody discuss what would happen if all HPI were 16 lost, unavailable for some reason?
17 A No.
18 MS. WAGNER: We have no further questions.
19 MR. KIRSCHBAUM: I have no questions.
20 (Time noted: 12:00 o' clock noon.)
21
(_ 22 William E. Potts 23 Subscribed and sworn to before me this day of 1982.
(') - 24
(./
25
- - , - - , .,c +,
, - - - - - , n e ,- -e .
1 252 l
) ,[k CERTIFICATE U
STATE OF NEW YORK )
3 [i : ss.:
COUNTY OF NEW YORK )
4 ,.!.
/
I, ROBERT CAPUZELo , a Notary
(,
l 6
Public of the State of New York, do hereby certify that the continued deposition of WILLIAM E. PoTTS was taken before 8
me on Friday, January 8, 1982 consisting of pages 177 through 250 ;
I further certify that the witness had g l
been previously sworn and that the within
( transcript is a true record of s' aid testimony; That I am not connected by blood or '
lo, marriage with any of the said parties nor interested directly pr indirectly 'in the matter in controversy, nor an I in the employ of any I j
i of the counsel. -
l 18 l
l IN WITNESS WHEREOF, I have hereunto set'my j 20 i handthis_AA -
day of J)WW ,1982.
{ l al I
(, .- f 23 I v
0, Al '
vLab #
l ROBERT CAPUZELo j 24 '
q" 25 ;
i !
i
-_-__.1
,, UNITED STATES DISTRICT COURT
( ) COUTHERN DISTRICT OF NEW YORK wJ
________________________________________x GENERAL PUBLIC UTILITIES CORPORATION, :
C' JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and :
PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 Civ. 1683 (RO)
-against- AFFIDAVIT THE BABCOCK & WILCOX COMPANY and McDERMOTT INCORPORATED, :
Defendants. :
________________________________________x STATE OF PENNSYLVANIA ) .
- ss.:
COUNTY OF DAUPHIN )
Il I have read the_ transcript of my deposition taken on O
January 8 and January 9, 1982 and together with the attached corrections, it is accurate to the best of my knowledge and belief.
4 i
/
WilliamE.]Potts Signed and sworn to before me this i d day of July, 1982.
Barbara A. Rote. Notary Pubfic fast Hempfie:,7.p., pg g,,, ,,
MF Commhort hp;;*3 A Sust 22 Aka d-@& Notary Public n
t i
'w/
Corrections to Deposition of William E. Potts January 8 and January 9, 1982 q
t
PAGE LINE CHANGE
- 6 7 "Id" should read "I" C' 8 12 " Health, Physics," should read
" Health Physics,"
- 9 8 In order to clarify my answer, add "I was employed by Metropolitan Edison Company while I was working at Saxton. In 1972 I went to work for Metropolitan Edison Company at Three Mile Island."
12 8 " operations maintenance" should read
" operations and maintenance" 28 8 "Who is" should read "He was" 28 13 In order to clarify my a'nswer, strike " Quality assurance specialist."
- )
\_j 34 11 In order to clarify my answer, insert "ever doing that" after
" recall" 34 15 In order to clarify my answer, insert "ever doing that" after
" recall" 56 13 "for" should read " form" 59 8 In order to complete my answer, add "It was set up, in part, for that purpose but I do not recall if there was any occasion for Met-Ed to make a Part 21 filing while I was at Licensing."
(. 59 11 In order to clarify my answer, strike the period after "know" and insert "if it still exists in the form it was in while I was at Licensing. Some form of action item system exists today."
- Unless otherwise stated, each correction is being 6ade to correct
( )y errors in typing or hearing by the reporter.
r 1
1 Corrections to Deposition.of William E. Potts January 8 and January 9, 1982 FAGE LINE CHANGE
{' 59 13 In order to complete my answer, replace the period after "No" with a comma and insert "but occasionally action items are referred to me for handling."
63 2 " Roan" should read " Ronald" 63 14 " Roan" should read " Ronald" 72 11 In order to clarify my answer, add "That position ceased to exist."
79 21 " Manager, Development" should read
" Management Development" t
98 18 " local" should read "LodA" 135 5 In order to complete my answer, replace the period after "No" with a comma and insert "not.before the O. accident. But since the accident I have seen documents which show that B&W knew that its high-pressure injection system wasn't safe to operate."
149 19 "2979" should read " March '79" 159 19-20 In order to clarify my answer, strike "I have no other reason to believe it" and insert "I'have no reason to believe that B&W 384 is not accurate" ,
203 5 " oxide" should read "off-site"
-- 210 21 " safe" should read " safety" ,
219 6 " benefit, provide" should read
" Benefit. He provided" 2
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